Anderson v. JPMorgan Chase, N.A., D/B/A Chase Home Finance, L.L.C., 4:11-cv-03346

Plaintiff Sylvester Anderson sues JPMorgan Chase in Texas state court seeking declaratory relief that Chase has no right to enforce the mortgage.
Chase removed the case to federal court based on diversity and an amount in controversy over $75,000.
Plaintiff argued the amount in controversy was not satisfied; the court denied remand, finding the remaining mortgage balance exceeded $75,000.
Prior memorandum concluded the remaining mortgage balance at removal exceeded $118,000, satisfying the §1332(a) amount threshold.
Plaintiff moved to reconsider; motion argued new theories about removal and evidentiary admissibility of a loan-affidavit.
Court denies reconsideration, reaffirming removal was proper and the disputed issues were previously addressed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the amount in controversy satisfied?	Anderson/Creditors argue removal fails on amount in controversy.	Chase contends remaining mortgage balance exceeds $75,000.	Yes; remaining balance exceeded $118,000.
Is the McGruder affidavit admissible under Rule 803(6)?	Affidavit improperly relies on loan records not attached.	Affidavit admissible; records need not be attached.	Admissible under Rule 803(6).
Did defendant’s alternative fair market value argument affect removal timing?	Argues alternative FMV analysis created improper second removal.	FMV alternative not relied on for the decision; not a second removal.	No; alternative argument not considered as second removal.
Should motion to reconsider be granted?	Resubmits the same remand arguments.	Arguments already addressed; no manifest error.	Denied; prior ruling correct.

Ross v. Marshall, 466 F.3d 745 (5th Cir. 2005) (reconsideration limited to manifest errors or new evidence)
Templet v. Hydrochem, Inc., 367 F.3d 473 (5th Cir. 2004) (reconsideration is an extraordinary remedy)
In re TranstexasGas Corp., 303 F.3d 571 (5th Cir. 2002) (limits on reconsideration and re-litigation)